S. 275 : Penalty – Bar of limitation – Takes or accepts any loan or deposit – Repayment of loan or deposit – Limitation period of six months to be reckoned from the end of month initiation of the penalty proceedings by JCIT and not from the date of assessment order – Penalty u/s2771D is independent under assessment .-JCIT is only authority competent to initiate proceedings and impose penalty – Not barred by limitation .[ S. 269SS, 269T,271D, 271E ]

S.260A: Appeal – – High Court – Inter department litigation-Clearance from the Committee on dispute – Order of High Court directing the CIT to approach the High Powered Committee for clearance of Committee on Dispute for filing appeal before the High court is set aside and matter remanded to High Court for deciding the appeal on merits .

S. 80HHC : Export business – Total turn over – Excise duty-Excise duty paid by assessee was to be excluded from the total turnover for purpose of computation of deduction .

Interpretation of taxing statues- Intention of legislature must prevail [ S. 10A,80HHC, 80HHE ]

Interpretation of taxing statues- Proviso- Amendment to remedy unintended consequences and make provision workable is to be treated as retrospective .[ S.40(a)(ia) ,139(1)]

Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015,
S.10(1): Offences and Prosecution — Undisclosed Foreign Income – Court cannot extend or reduce time contrary to statutory provisions – Summons issued only after notices were issued — Issue of parallel proceedings is question of fact — A writ of prohibition could not be issued to prevent the authorities from initiating prosecution, as that would render the provisions of section 48 inoperative.[ S.10(3) 11(1) 48 , Art .226 ]

S. 271(1)(c) : Penalty – Concealment – Capital gains —Claiming exemption under S.10(38) with a note that reserved its right to carry forward the loss – Deletion of penalty is held to be justified [ S.10(38), 45 ]

S. 226 : Collection and recovery – Modes of recovery -Attachment of bank account – Interim in junction was granted subject to payment of 20 percent of disputed tax on account of claim of additional depreciation .[ S 32(1)(iia), 226(3) ]

S.147: Reassessment- Recording of reasons is mandatory -Capital gains- Inflated cost of indexation of land- The Assessing Officer cannot supply reasons from any material or grounds outside the reasons recorded by him -Notice issued without application of mind is held to be in valid [ S.148 ]

S. 147 : Reassessment -Capital gains- Sale of land on the basis of valuation by Government approved valuer -Reassessment notice based on the valuation by Valuation officer is held to be bad in law [ S.148 ]